Effective Date of Current Policy: May 24, 2018

Sustainable Insight Capital Management and its affiliates (“we”, “us” or “our”) are committed to protecting the security and privacy of your personal information. This Privacy Policy seeks to help you understand our collection, processing and disclosure of personal information in connection with this website. For the purposes of EU data protection laws, Sustainable Insight Capital Management LLP is the data controller (i.e. the company responsible for, and which controls the processing of your personal information).

Personal Information We May Collect About You

When you contact us using the Subscribe button on the website, any personal information submitted (e.g. your name, residential address, telephone number, company name or email address) will be collected and processed by us.

In addition, we may automatically collect basic technical information from all visitors to the website. We collect technical information during your visit to the website through our automatic data collection tools, which may include cookies and other commonly used technologies (e.g. web beacons). Please see the Section on Cookies below for further information.

We may also collect personal information from you via subscription documents or other related forms, through transactions you may have with us, or through sign-up sheets or business cards obtained at events we host or attend.

How We Use Your Personal Information

We maintain physical, electronic and procedural protections that comply with US federal standards to safeguard nonpublic personal information and which we believe are adequate to prevent unauthorized disclosure of such information. The provision of personal information by you may be necessary where we have a legitimate interest to carry out the following purposes: (i) to provide investment advisory services; (ii) to contact you and respond to your enquiry or provide you access to specific information or offers; (iii) to support our relationship with you; (iv) to understand how we can improve our products and services; (v) to personalize your visit to the website and to assist you while you use the website; (vi) to send marketing communications to you; (vii) to improve the website by helping us understand who uses the website; and (viii) to comply with applicable laws, regulations or codes of practice.

Please note that you have a right to object to the processing of your personal information where that processing is carried out for our legitimate interest or for direct marketing.

Sharing Your Personal Information

We may contract with selected third parties to provide us with services, including legal advisors, auditors and accountants, fund administrators, transfer agents, custodians and trustees. We may also retain companies that provide us with technical support and assistance in respect of the website and companies engaged to contact you about an offer in support of your business needs or to conduct online surveys to understand better our customers’ needs. All service providers are permitted to use data only for the purpose of performing services on our behalf in compliance with our privacy practices and policies. Our affiliates may also have access to personal information provided to us by you including through or in connection with this website for the purposes set out in this Privacy Policy.

The servers used in the operation of the website automatically identify a computer by its IP address. If we, in good faith, determine that you have or are attempting to misuse or harm the website, we may investigate and cooperate with appropriate law enforcement agencies to protect our rights or property.

Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise.

E-Mail Communications and Marketing

Occasionally, we may send you e-mail communications with information that may be useful to you, including information about our products and services, its subsidiaries and other third parties with whom we have a commercial relationship. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional e-mails from us. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing or market research communications from us, or would like to stop processing your personal information in any other way, you can contact us as described below to let us know what types of communications you wish to stop receiving. However, if you are a customer, supplier or otherwise have a commercial relationship with us, to ensure that you receive important information, you agree that we may send you non-marketing related information when necessary. We do not disclose, sell or otherwise market your personal information to third parties, unless we are required to do so by law.

For Residents of the European Economic Area (the “EEA”)

Given the global nature of our activities, where you are located in the EEA, personal information collected from you, including via the website, may be transferred to affiliated entities in countries located outside the EEA, including the U.S., which are not considered by the European Commission to provide an adequate level of data protection.

You hereby expressly consent to the transfer of your personal information to recipients (including us), as described in this Privacy Policy, which are located outside of the EEA. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

We have entered into EU standard contractual clauses (“Model Contracts”) for intra-group transfers of personal information. You can request a copy of these Model Contracts by submitting your request via email to: info@sicm.com.

Rights of European Residents

Individuals in Europe have certain data subject rights which may be subject to limitations and/or restrictions. These rights may include: (i) the right to request access to and rectification or erasure of their personal information; (ii) the right to obtain restriction of processing or to object to processing of their personal information; and (iii) the right to ask for a copy of your personal information to be provided to you, or to a third party, in a digital format. If you are based in the EEA and would like to exercise one of the abovementioned rights, please send us your request via email to: info@sicm.com. Individuals in the EEA also have the right to lodge a complaint about the processing of their personal information with their local data protection authority.

Links to Other Websites

Our website contains links to other websites. We are not responsible for the privacy practices or the content of other websites. This Privacy Policy applies only to the information we collect through our website. We encourage you to read the privacy statements of all of the destination websites which you visit.

Security

We use various methods to ensure the protection of your personal information against accidental or unlawful destruction, loss or alteration and against unauthorized disclosure or access. While these methods are considered to be effective, we do not guarantee the protection of your personal information as no data transmission over the Internet can be guaranteed to be completely confidential or 100% secure. You use our website and provide all such personal information at your own risk. We retain personal information for as long as necessary to fulfil the purposes for which such personal information was collected or to comply with its legal obligations, resolve disputes or enforce agreements. The criteria used to determine the retention periods include: (i) how long the personal information is needed to provide the services and operate the business; (ii) the type of personal information collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

When you visit the website, we may place a “cookie” or other online tracking device (e.g. web beacons) in order to improve your experience by recognising you when you visit the website, such as by assigning a session ID and to deliver content specific to your interests. The cookies we place may also collect information about your IP address, or click stream data within our website (i.e. the actions taken in connection with the website). This information helps us improve the functionality of the website.

We also use cookies provided by Google Analytics to help us measure how visitors use the website. The information collected is used for a variety of purposes, including, but not limited to, site traffic reporting, unique visitor counts, and content optimization. Although Google Analytics logs the information coming from the website on our behalf, we control how the data may and may not be used. If you do not want to help us learn how to improve the website, you can opt-out of this website analysis tool by clicking: https://tools.google.com/dlpage/gaoptout.

Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the website.

Revisions to Our Privacy Policy

We evaluate our privacy policies and procedures to implement improvements and refinements from time to time. If we make any material changes to this Privacy Policy we will notify you by means of a prominent notice on the website prior to the change becoming effective. We will also post an updated version on our website. Please check our website periodically for updates.

Questions and Comments

If you have any questions or comments about our Privacy Policy or, if you are based in the EEA and would like to exercise your data subject rights, please feel free to contact us at info@sicm.com.